What we handle
Every case is different. We evaluate every option available under current tax law and pursue the best outcome for your specific situation.
A formal IRS program that may allow a tax liability to be resolved for less than the full balance, where the taxpayer qualifies based on income, expenses, asset equity, and future earning capacity. Qualification is strict and most applicants do not meet the standard. We assess honestly whether you do before filing anything, because a rejected offer costs time and leaves you worse positioned.
Structured payment arrangements that stop active collection and make a balance manageable. Several types exist, and the right one depends on the amount owed, your financial position, and whether the IRS has begun enforcement. Getting the structure right the first time matters, because a defaulted agreement is harder to replace than the original was to obtain.
When the IRS levies wages or a bank account, the priority is stopping the collection action and then addressing the underlying liability. Levy releases are available in defined circumstances, and there are appeal rights attached to most enforcement notices that expire if not exercised in time.
The IRS assesses penalties for late filing, late payment, and failure to deposit. Relief is available in defined circumstances, including first-time abatement and reasonable cause. We identify which grounds actually apply to your facts rather than filing a generic request.
Unfiled returns block access to nearly every resolution option, and the IRS may prepare substitute returns that overstate what is owed. Getting compliant comes first. Filing does not trigger anything that was not already coming, and it frequently reduces the assessed balance.
Certain lien and levy notices carry the right to a hearing before an independent IRS Appeals officer, and that right expires on a fixed deadline. A timely request pauses collection while the hearing is pending and preserves the ability to seek Tax Court review.
Employment tax delinquency, Revenue Officer representation, and defense against Trust Fund Recovery Penalty assessment under IRC § 6672. Payroll tax is the IRS's highest collection priority and can be assessed against owners and officers personally.
When administrative options are exhausted or the IRS position is wrong on the law, litigation is available. Tim has 25 years of federal litigation experience. Non-attorney firms cannot follow a case into court.
Outcomes depend on individual facts, financial circumstances, and current IRS standards. Nothing on this page is a prediction or guarantee of any particular result.
Business owners
If your business is behind on 941 deposits, the trust fund portion can be assessed against you personally — and that assessment survives closing the business.
Ready to take the first step?
Confidential case evaluation — no pressure, no obligation. Tim Wooten will personally review your situation.
Gower, Wooten & Darneille, LLC · 4200 Northside Parkway NW, Building 12, Atlanta, Georgia 30327